Privacy Policy

This Privacy Policy applies to information collected directly by Clarity Wellness Coaching through:

• Clarity websites;
• Coaching programs;
• Educational programs and courses;
• Digital products and resources;
• Membership programs;
• Client communications;
• Scheduling systems;
• Email and text communications;
• Community programs;
• Virtual coaching sessions;
• Customer support;
• Surveys and questionnaires;
• Social media interactions;
• Affiliate and referral programs; and
• Other Clarity-operated services.

This Privacy Policy does not replace the privacy policies or Notices of Privacy Practices applicable to medical services provided through Altro Health, independent medical providers, medical groups, pharmacies, laboratories, or other healthcare entities.

When you leave a Clarity-controlled website and access the Altro Health platform or another third-party healthcare platform, information submitted through that platform is governed by the privacy policies, terms, consent forms, and healthcare privacy requirements applicable to that platform and its participating healthcare entities.

Clarity Wellness Coaching provides wellness education, coaching, and non-clinical support. Medical services are accessed separately through the Altro Health platform and are provided by independent licensed medical providers. Clarity does not make medical decisions.

All decisions regarding:

• Medical eligibility;
• Diagnosis;
• Whether a treatment is appropriate;
• Whether a prescription will be issued;
• Medication selection;
• Medication dosage;
• Treatment changes;
• Clinical monitoring; and
• Continuation or discontinuation of treatment

are made solely by licensed medical providers exercising independent clinical judgment. When a prescription is medically appropriate, it is issued by the applicable licensed medical provider and fulfilled by a participating licensed pharmacy. Clarity does not direct, supervise, control, or interfere with medical judgment or prescribing decisions.

Clarity Wellness Coaching and Altro Health maintain separate payment relationships with clients.

Medical-related payments

All payments associated with medical treatment accessed through Altro Health are processed separately through the Altro Health platform. Clarity Wellness Coaching does not collect, process, or retain payment for:

• Medical consultations;
• Clinician evaluations;
• Medical treatment;
• Prescription medications;
• Pharmacy fulfillment;
• Medical treatment subscriptions;
• Medical treatment refills;
• Medical provider fees; or
• Other medical services purchased through Altro Health.

Medical-related billing questions, cancellations, refunds, or payment issues are governed by the policies applicable to Altro Health and the applicable independent medical provider, pharmacy, laboratory, or other healthcare entity.

Clarity payments

Clarity may separately collect payment for Clarity-specific non-medical services, including:

• Wellness coaching;
• Coaching programs;
• Educational programs;
• Digital guides or resources;
• Courses;
• Membership programs; and
• Other non-medical services offered directly by Clarity.

Payments for Clarity services may be processed by third-party payment processors. Clarity does not intentionally store complete credit or debit card numbers on its own systems.

Depending on how you interact with Clarity, we may collect the following categories of information.

A. Contact information

• Name;
• Email address;
• Telephone number;
• Mailing address; and
• Preferred method of communication.

B. Account & scheduling information

• Account credentials;
• Appointment information;
• Time zone;
• Scheduling preferences;
• Program enrollment information; and
• Communication preferences.

C. Coaching & wellness information

If you participate in a Clarity coaching program, you may voluntarily share information relating to:

• Wellness goals;
• Nutrition;
• Exercise;
• Lifestyle;
• Sleep;
• Habits;
• Progress;
• Body-composition goals;
• Motivation;
• Challenges; and
• Other information relevant to your coaching experience.

Clarity coaching is not medical care. Information intended for medical evaluation, diagnosis, prescribing, medication management, or treatment decisions should be submitted directly through the secure medical intake or patient portal provided through Altro Health rather than through Clarity email, text messages, social media, coaching forms, or general website forms.

D. Communications & content

We may collect information contained in:

• Emails;
• Text messages;
• Client-support requests;
• Surveys;
• Questionnaires;
• Testimonials;
• Reviews;
• Uploaded content;
• Coaching communications; and
• Other information you voluntarily submit to Clarity.

E. Payment information

When you purchase coaching, educational products, memberships, or other non-medical Clarity services, payment information may be processed by third-party payment processors. Clarity does not intentionally store complete credit or debit card information. Medical-treatment payment information is processed separately through Altro Health and is not collected by Clarity.

Information required for medical evaluation or treatment should be submitted directly through the applicable secure medical intake process or patient portal available through Altro Health. Information requested during that process may include:

• Medical history;
• Current medications;
• Allergies;
• Health conditions;
• Previous treatments;
• Laboratory results;
• Height and weight;
• Treatment goals;
• Identification information;
• Prescription information; and
• Other information required by the licensed medical provider.

Clinical information submitted through Altro Health or another medical platform may be collected, processed, or maintained by Altro Health, independent medical providers, medical groups, pharmacies, laboratories, or other healthcare entities involved in your care. Clarity does not independently create or maintain your medical chart.

Depending on the services involved, Clarity may receive limited administrative or coordination information when reasonably necessary to assist with customer support, coaching coordination, or other non-clinical functions. Clarity does not use access to any such information to influence medical eligibility, prescribing, dosing, or other clinical decisions.

Requests regarding medical records, laboratory results, prescriptions, treatment records, clinician communications, or healthcare privacy rights should be directed to the applicable medical provider or through the appropriate Altro Health patient-support channel.

When you visit a Clarity website, certain information may be collected automatically. This may include:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Referring website;
• Pages viewed;
• Date and time of visits;
• Approximate geographic location derived from IP address;
• Website interactions;
• Session information; and
• Similar technical information.

We may collect this information through cookies, analytics technologies, pixels, tags, SDKs, or similar technologies.

Clarity may use personal information to:

• Provide coaching and educational services;
• Manage client accounts;
• Schedule appointments;
• Personalize coaching experiences;
• Provide customer support;
• Communicate about purchases and services;
• Send appointment reminders;
• Process payments for Clarity services;
• Provide access to courses, guides, memberships, and digital resources;
• Coordinate non-clinical support requested by clients;
• Direct clients to appropriate Altro Health or medical-provider resources when necessary;
• Maintain and improve our websites;
• Analyze website performance;
• Prevent fraud and misuse;
• Protect our business and users;
• Maintain tax, accounting, and business records;
• Respond to lawful legal requests;
• Enforce our agreements; and
• Comply with applicable law.

With your consent where required, we may also use contact information to send educational content, newsletters, program announcements, promotions, special offers, and affiliate offers.

Information related to health, wellness, medications, treatments, reproductive health, mental or physical conditions, or other health-related matters may be considered sensitive information or consumer health data under certain state privacy laws. Clarity treats such information with heightened care.

Clarity does not sell identifiable:

• Medical intake information;
• Prescription information;
• Laboratory results;
• Medical records; or
• Clinical communications

to data brokers or advertisers. Clarity does not use information submitted through Altro Health medical intake or clinical portals to create advertising profiles or target individuals with advertising.

Where applicable law requires consent before Clarity collects, processes, or discloses sensitive or consumer health information, we will obtain the required consent. Additional consumer-health privacy rights may apply depending on your state of residence.

Service providers

We may use third-party companies to help operate our business, including providers of:

• Website hosting;
• Payment processing for Clarity services;
• Scheduling;
• Email services;
• Text-message services;
• Customer relationship management;
• Video conferencing;
• Cloud storage;
• Accounting;
• Analytics;
• Cybersecurity;
• Customer support; and
• Business administration.

These service providers may process information as necessary to perform services on our behalf.

Altro Health & healthcare service providers

When you independently choose to access medical treatment through Altro Health, your information may be collected and processed through Altro Health and participating medical providers, medical groups, pharmacies, laboratories, and other healthcare service providers. Clarity generally directs clients to submit medical information directly through the appropriate secure medical platform.

Legal, safety & compliance

We may disclose information when reasonably necessary to:

• Comply with applicable law;
• Respond to lawful subpoenas, court orders, or government requests;
• Investigate fraud;
• Enforce agreements;
• Protect our services; or
• Protect the rights, property, or safety of Clarity, our clients, or others.

Business transactions

If Clarity is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, information may be transferred as part of that transaction, subject to applicable privacy requirements.

Clarity does not sell identifiable medical information for monetary compensation. We do not provide medical intake information, prescription information, laboratory results, or confidential clinical communications to advertisers for targeted advertising.

Certain website analytics, affiliate attribution, or advertising technologies used on general informational portions of our website may involve disclosures that some state privacy laws define as “sharing,” “targeted advertising,” or a “sale,” even when no money is exchanged for the information. Where required by applicable law, appropriate privacy choices or opt-out mechanisms will be provided.

Clarity websites may use cookies and similar technologies to:

• Operate website functionality;
• Remember preferences;
• Understand website traffic;
• Measure performance;
• Prevent fraud;
• Measure marketing effectiveness; and
• Attribute affiliate or referral activity.

We may use services such as Google Analytics, Meta technologies, or similar platforms on general informational and marketing portions of our websites. These technologies are not intended to receive medical intake responses, prescription information, laboratory results, clinician communications, or information entered into Altro Health’s secure medical environment. Medical intake, clinical, and patient-portal information is handled separately through the applicable medical platform.

Users may manage cookies through available website controls or their browser settings. Disabling certain cookies may affect website functionality.

Clarity may participate in affiliate or referral programs. If you click an affiliate link, the third-party merchant may use cookies, referral codes, or similar technologies to determine that a purchase originated from Clarity. Clarity may receive compensation for qualifying purchases.

Affiliate partners maintain their own privacy policies and terms. Clarity does not provide medical intake information, laboratory results, prescriptions, or confidential clinical records to affiliate merchants for marketing purposes.

When you provide your email address or telephone number, Clarity may send communications relating to purchases, coaching appointments, account activity, customer support, program information, service announcements, and policy updates. With appropriate consent, we may also send educational content, newsletters, special offers, program announcements, product information, and affiliate promotions.

You may unsubscribe from marketing emails using the unsubscribe link contained in the email. You may opt out of marketing text messages by replying STOP. Standard messaging and data rates may apply. Opting out of promotional communications does not prevent Clarity from sending necessary transactional, account, safety, or service-related communications.

Clarity may use Zoom or similar technologies for individual and group coaching sessions. Sessions will only be recorded by Clarity when appropriate notice and consent have been provided. Participants may not record, screenshot, reproduce, or redistribute private coaching or group-session content without authorization.

Group coaching and community environments should not be used to disclose information you do not want other participants to know. Confidential clinical concerns, medication questions, medical side effects, or medical emergencies should be directed to the appropriate licensed medical provider rather than discussed during a group coaching session.

Clarity may operate accounts or communities through platforms including Facebook, Instagram, TikTok, YouTube, and other social or community platforms. Information you voluntarily post on those platforms may be visible to others and is subject to the privacy practices and terms of the applicable platform.

Please do not submit confidential medical information through:

• Public comments;
• Social-media posts;
• Direct messages;
• Facebook groups; or
• Other public or community communications.

If you contact Clarity through social media regarding a clinical matter, we may direct you to the appropriate secure Altro Health or medical-provider communication channel.

Clarity Wellness Coaching provides wellness education, coaching, and non-clinical support and is not the medical practice providing your clinical care. Medical and clinical services accessed through Altro Health are provided by independent licensed healthcare professionals.

Information submitted directly to a medical provider through a secure medical intake or patient portal may be protected under HIPAA or other healthcare privacy laws and will be handled in accordance with the healthcare entity’s applicable Notice of Privacy Practices. Information voluntarily provided directly to Clarity for coaching purposes should not automatically be assumed to constitute a medical record merely because it relates to your health or wellness.

Clients should submit information intended for:

• Diagnosis;
• Prescribing;
• Medication management;
• Clinical treatment;
• Medical evaluation; or
• Medical-record purposes

through the appropriate secure medical channel. Nothing in this Privacy Policy limits any healthcare privacy rights you may have under applicable law.

Clarity uses reasonable administrative, technical, and organizational safeguards designed to protect personal information within our control. Depending on the information and system involved, these safeguards may include:

• Access controls;
• Password protection;
• Secure hosting;
• Encryption in transit;
• Limited employee or contractor access;
• Confidentiality requirements; and
• Security practices appropriate to the nature of the information.

No electronic system, website, transmission method, or database can be guaranteed to be completely secure. Users are responsible for protecting the confidentiality of their own usernames, passwords, and account credentials.

If Clarity discovers a security incident involving personal information within our control, we will investigate and take appropriate action consistent with applicable law. Where legally required, this may include notification to affected individuals, government agencies, service providers, business partners, or other required parties.

Altro Health, medical providers, pharmacies, laboratories, and other healthcare entities are responsible for security and breach-notification obligations applicable to information maintained within their respective systems.

Clarity retains personal information for as long as reasonably necessary to provide services, maintain business and financial records, resolve disputes, enforce agreements, comply with legal requirements, and fulfill the purposes described in this Privacy Policy. Different categories of information may be subject to different retention periods.

Medical providers, pharmacies, laboratories, Altro Health, and other healthcare entities may retain medical, clinical, or transaction records according to their own legal, regulatory, contractual, and clinical requirements.

Depending on your state of residence, the laws applicable to Clarity, and the type of information involved, you may have certain privacy rights. These may include the right to:

• Confirm whether we process personal information about you;
• Request access to certain personal information;
• Request correction of inaccurate information;
• Request deletion of certain personal information;
• Obtain a portable copy of certain information;
• Withdraw consent where processing is based on consent;
• Opt out of certain targeted advertising or data-sharing activities;
• Limit certain processing of sensitive information;
• Appeal certain privacy-request decisions; and
• Exercise legally protected privacy rights without unlawful discrimination.

Not every right applies in every jurisdiction or circumstance, and legal exceptions may apply. To submit a privacy request, contact info@claritywellnesscoaching.com and include “Privacy Request” in the subject line. We may take reasonable steps to verify your identity before completing a request. If applicable law provides a right to appeal a decision, you may submit an appeal by replying to our response with “Privacy Appeal” in the subject line.

Residents of states with comprehensive consumer privacy laws may have additional rights concerning their personal information. These states may include, but are not limited to, California, Colorado, Connecticut, Virginia, Utah, and other states that adopt applicable consumer privacy laws.

The availability of any particular right depends on whether the applicable privacy law applies to Clarity, the individual, and the specific processing activity. Where required by law, Clarity will provide applicable notices, consent mechanisms, opt-out methods, or other privacy rights. Clarity will not unlawfully discriminate against individuals for exercising legally protected privacy rights.

Certain states provide additional privacy protections specifically for consumer health information, including certain health-related information that may not otherwise be subject to HIPAA. Depending on applicable law, individuals may have additional rights concerning:

• Collection of consumer health data;
• Use of consumer health data;
• Disclosure of consumer health data;
• Withdrawal of consent;
• Access;
• Correction;
• Deletion; and
• Other processing activities.

Where required by applicable law, Clarity may provide a separate Consumer Health Data Privacy Policy or additional consumer health data notice.

Clarity’s websites, coaching programs, medical-access services, and other offerings are intended for individuals age 18 and older. We do not knowingly collect personal information from children under 18 through services intended for adults. If you believe a minor has improperly provided personal information to Clarity, please contact info@claritywellnesscoaching.com. We will review the request and take appropriate action.

Clarity websites may contain links to:

• Altro Health;
• Medical providers;
• Pharmacies;
• Laboratories;
• Product manufacturers;
• Affiliate merchants;
• Social-media platforms; and
• Other third-party services.

When you leave a Clarity-controlled website or service, the privacy practices and terms of the applicable third party may apply. Clarity is not responsible for the privacy practices of independently operated third-party websites, medical providers, pharmacies, laboratories, or platforms. We encourage users to review applicable privacy policies before providing personal information.

Clarity’s services are operated from the United States and are primarily intended for individuals located in the United States. If you access our websites from another country, information may be transferred to and processed in the United States. Applicable privacy rights may differ depending on your location.

Some internet browsers and devices offer privacy preference signals, including “Do Not Track” or other universal opt-out mechanisms. Because there is not one universally applicable standard governing all such signals, website responses may vary.

Where applicable law requires Clarity to recognize a legally recognized privacy preference or universal opt-out signal, Clarity will honor the signal as required. Users may also manage certain tracking technologies using available cookie controls or browser settings.

Clarity may update this Privacy Policy periodically to reflect changes in our services, technology, vendors, business relationships, privacy practices, or applicable law. The current version will be posted on our website with the applicable Last Updated date. Where required by law, material changes involving sensitive information or materially different data practices will be accompanied by additional notice or consent.